About the OTOP
The OTOP sub-region is bordered by the Rangitata River in the north and the Lyalldale Creek in the south, the Pacific Ocean to the east and Main Divide in the west (See Map). Within the OTOP sub-region are the Orari, Temuka, Opihi, Opuha, Te Ana Wai and Pareora Rivers and associated tributaries. Other notable geographical features within the OTOP sub-region include Lake Opuha and the Opuha Dam.
There are three distinct groundwater areas in the OTOP sub-region, the inland basins, the coastal plains and the downlands. The quality of groundwater is influenced by geology, depth, land use and recharge sources. In those areas where groundwater recharge is dominated by drainage from the soil (as opposed to from river sources), excess nitrates can be carried into groundwater.
Submissions on PC7 opened on 20 July 2019 and closed on 13 September.
DairyNZ's submission position
DairyNZ supports proposals by Environment Canterbury for dairy farmers in Waimakariri and South Canterbury to continue to reduce their nitrogen losses over the next decade.
Water quality is affected by a range of activities - including urban and lifestyle activities, dairy farming and other types of agriculture, horticulture and arable farming.
DairyNZ supports the objectives of Plan Change 7 as we believe they will help our vision to improve water quality. We recognise that dairy farmers are a key part of the solution to meeting our community’s water quality aspirations and need to be leading a community response.
Dairy farmers in Canterbury have already invested in fencing off waterways, riparian planting and implementing good management practices as part of existing Farm Environment Plans. The Farm Environment Plans farmers now have in place will continue to develop to reflect changes in best practice environmental management.
In its submission on Plan Change 7 to the Canterbury Land and Water Regional Plan, DairyNZ supported Environment Canterbury’s proposals for dairy farms to achieve a 15% reduction in nitrogen losses in Waimakariri and a 10% reduction by 2030 in the Orari Temuka Opihi Pareora zone.
DairyNZ is already working with Canterbury farmers and a number of supporting organisations to develop a range of practical options farmers can adopt to help them achieve future nitrogen loss targets.
We also recognise that further reductions in nitrogen loss will be needed on-farm after 2030. DairyNZ supports an adaptive management approach being adopted by Environment Canterbury after 2030 - where targets for nitrogen losses on farms are set based on the most recent comprehensive water quality data available.
DairyNZ supports more work being undertaken to develop robust groundwater hydrogeological modelling to provide greater certainty on the direction of groundwater flows from the Waimakariri zone. The submission also supported improving the accuracy of Overseer calculations of nitrate losses in soil and undertaking a more robust socio-economic impact assessment of future proposals.
We noted in our submission that in a number of areas where nitrate levels are modelled as increasing in the future, existing trends show that nitrate levels are declining or stable. The plan change needs to be updated to reflect the results of recent water quality monitoring data.
We would like to see a partnership approach adopted between farmers, the community, councils and water zone committees to design and implement a robust water quality monitoring regime. This would provide everyone with a good basis for making well-informed future decisions which affect us all.
You can read DairyNZ’s full submission online, which has more detail on our position.
Environment Canterbury's future process
Following the close of submissions, Environment Canterbury is preparing a summary of decisions requested document. This summary of submissions will be notified shortly. The period for making a further submission will be from 18th to 29th Note: you are only allowed to make a further submission on others’ submissions if you made an original submission.
After this, a public hearing of submissions and evidence will happen. The hearing, in front of an independent hearing panel, is likely to be held during the first half of 2020.
The independent hearing panel will prepare a set of recommendations for Environment Canterbury to consider and potentially adopt as its decision.
For more information on the Plan Change process and updates, visit the Environment Canterbury website.
Key changes under Proposed Plan Change 7 for OTOP
Reducing nitrogen losses
PC7 establishes High Nitrogen Concentration Areas (HNCAs) in the Rangitata Orton, Fairlie Basin and Levels Plains areas. Within HNCAs there is a requirement for farming activities to further reduce nitrogen losses beyond Baseline GMP Loss Rates (determined by the farm portal) to assist with achieving water quality targets for ecosystem health and drinking water outcomes. The following nitrogen loss reductions would apply for dairy farming under the proposed plan change:
- All farms meet baseline Good Management Practice (bGMP) by 2020
- In the Rangitata Orton, Fairlie Basin and Levels Plains areas reduce nitrogen loss by 10% (for dairying) and 5% (other farming activities) beyond bGMP by 2030
- In Rangitata-Orton and Levels Plains reduce nitrogen loss by 20% beyond bGMP by 2035
High Nitrogen Concentration Area tagged Reductions
Outside the High Nitrogen Concentration Areas, farmers are required to carry out actions to manage run-off and sediment from their farms
Further detail on the proposed plan change can be found here.
Surface water quality
Reports show the current state surface water quality within the sub-region:
- Upper reaches of the catchments generally being in a healthy state, with low bacterial and nutrient levels, low levels of nuisance periphyton or cyanobacterial cover and healthy invertebrate communities.
- Nuisance levels of periphyton biomass and cyanobacterial blooms being common in mid to low reaches of many hill-fed rivers, affecting recreational and amenity values as well as affecting ecological and fishery values.
- Flows being a critical driver of ecosystem health, recreation and amenity values in hill fed rivers.
Key localised surface water quality issues within the sub-region include:
- Generally, spring fed streams in the sub-region are in a poorer state than hill-fed rivers.
- Spring-fed streams of the northern Orari River exceed the NPSFM* National Bottom Line for nitrate toxicity.
- Waitarakao/Washdyke Lagoon has high mahinga kai values and is recognised as a regionally important wildlife refuge. Concentrations of nutrients (total phosphorous and total nitrogen) and E.coli in the lagoon exceed NPSFM National Bottom Lines for respective contaminants.
- The Ring and Seadown Drains exceed the NPSFM National Bottom Line for nitrate toxicity.
*NPSFM- National policy statement for freshwater management
Flows and allocation
New environmental flow and allocation regimes have been proposed for parts of the OTOP sub-region. Higher minimum are proposed to be introduced over time, which would ensure more water is retained in the river to provide for ecosystem values. It is anticipated new the inclusion of higher minimum flows for rivers and additional restrictions on farming activities may help reduce algal blooms in rivers. An increase to minimum flows would reduce the reliability of water for abstractors. However, the introduction of new minimum flows have been staged, allowing time for irrigators and industry to adapt to proposed changes.
The changes proposed in PC7 for water takes include:
- The establishment of environmental flow and allocation regimes on the North and South Opuha, Upper Opihi and Te Ana Wai rivers, which include increased minimum flows and capped allocation limits;
- The establishment of an alternative management regime for the Opihi mainstem with alternative minimum flow levels which respond to drying climatic conditions; An alternative regime is proposed to manage releases of water from the Opuha Dam. Allocation of freshwater has been capped at current rates and partial restrictions are proposed to prevent minimum flows for the river from being breached.
- Within the Temuka area, an increase in the minimum flow, reduction in the allocation limit, setting of pro-rata partial restrictions, and the reservation of water for mahinga kai purposes; The water in the Temuka area is over-allocated and experiences high abstractive pressure. A range of flow and allocation regime is proposed with prohibitions on the transfer of water, increases to minimum flows for the Temuka River and its tributaries, and phasing out of over-allocation through reductions in allocation limits over time (at 3, 5 and 8 year intervals).
New region wide rules under PC7 are proposed:
- Prohibit farmed cattle, deer or pigs from disturbing or using the bed of lakes, rivers or permanently or intermittently flowing open drain within specified distance of sensitive areas such as intakes for community drinking water supplies, or indigenous freshwater species habitat.
- Prohibit farmed cattle, deer or pigs from disturbing or using the bed and banks of spring-fed plains rivers.
- Require consent, as a non-complying activity, for the use and disturbance of the bed and banks of lakes, rivers that are greater than 1m wide or 100m deep, or a wetland, by intensively farmed stock. Intensively farmed stock is defined in the CLWRP as cattle or deer grazed on irrigated land or contained for break-feeding of winter feed crops; dairy cattle, including cows, whether dry or milking, and whether on irrigated land or not; or farmed pigs.
- Permit stock to use the beds of lakes, rivers or wetlands for temporary or permanent access provided the access meets standards relating to water quality and physical disturbance of the bed or banks, and provided the activity is not classified as non-complying or prohibited.
Tangata Whenua and mahinga kai
Freshwater quality and quantity within the Orari-Temuka-Opihi-Pareora sub-region provides for the abundance of freshwater mahinga kai that are safe to gather, harvest and consume or use by:
- freshwater quality achieving the freshwater limits and targets;
- improving flows in hill-fed and spring-fed rivers;
- reserving an allocation of water from the Temuka Freshwater Management Unit, for the enhancement of mahinga kai and associated tangata whenua values;
- requiring all farming activities which include winter grazing or irrigation and that include or directly adjoin a surface water body within the Mātaitai Protection Zone, to operate at Good Management Practice and prepare and implement an audited Farm Environment Plan in accordance with Schedule 7.
- Protect wāhi tapu, wāhi taonga and nohoanga in the Orari-Temuka-Opihi-Pareora sub region by avoiding as a first priority adverse effects on these sites, and where avoidance is impracticable, requiring adverse effects on wāhi tapu, wāhi taonga and nohoanga to be minimised.
- Ngāi Tahu values associated with tuhituhi neherā (rock art) and waipuna (springs) and freshwater mātaitai in the Orari-Temuka-Opihi-Pareora sub-region are protected by: a. defining a Rock Art Management Area and a Mātaitai Protection Zone; and b. requiring, for any application to use land for a farming activity, to take and use water, or to discharge contaminants, an assessment of the
- actual and potential effects of the proposal on springs, freshwater mātaitai and/or rock art;
- the implementation of actions or methods to avoid or minimise adverse effects.
For further information contact:
Catchment Engagement Leader
DairyNZ has submitted on PC7. A copy of the DairyNZ submission can be found here.